LETTER: Cultivators selling clones is safest for patients

Cannabis is an unarguably complex plant. As a consumer for more than two decades, I have had a wide range of experiences from consuming it, not all of which have had the therapeutic benefit I now look for.

I understand that the Department’s draft rules regarding the sales of cannabis plants at any stage likely have a well-intended purpose, but I worry that there may have been some voices absent from that discussion. In particular, as a patient and caregiver, I want to point out that one of the safest ways to ensure that the plant a patient or caregiver is growing has the desired therapeutic benefit is to start from using a plant cutting. The safest way to do this in a legal market is to obtain this cutting from a licensed, reputable source, given the additional layer of regulatory scrutiny on commercial harvesters and distributors, when compared to caregiver and patient cultivation requirements.

The benefit of starting from a plant cutting for a patient or caregiver cultivator is two-fold:

• When a patient finds a strain that has an ideal therapeutic benefit, they can obtain an exact genetic replica through the same commercial channel, cultivating that plant and increasing the likelihood that the form of medicine that has been most effective for them will be available despite any changing whims of the market.
• It decreases the likelihood of issues of plant growth for new cultivators. This benefit accrues for several reasons, but two have to do with plant health and sexing. An established cutting’s health can be verified, whereas a seed’s growth prospects are much more uncertain. Another benefit is that starting from a cutting decreases issues related to plant sexing for newer patient cultivators, as it is typical that the cuttings sold are all female (flowering/medicine-producing) plants. For a newer cultivator, starting from cuttings may increase the likelihood that the medicine that they produce is of the quality one might obtain from a licensed, commercial facility, given the quality issues that can result from the presence of male plants.

Again, given the complexity of the cannabis plant and the wide-range of therapeutic uses patients in our state have been approved for, I believe it is in the best interests of patients to allow for the sale of live cannabis plants. Additionally, I would find it quite ironic if the practice most commercial cultivators use to propagate their plants was prevented from being commercialized itself, given the potential for it to enhance the quality of the medicine being produced by patient and caregiver cultivators. I hope you will consider these thoughts in the spirit with which they are offered, which is one of support for patient access and safety.

Sincerely yours,

Charles Cookson, DBA